Earlier this year, the Federal Trade Commission (FTC) announced that it wanted to investigate how to protect kids from stealth advertising in digital media. We see this opportunity as a follow-up to concerns we outlined to the FTC in 2020.
Much of what the FTC has in mind for protecting kids involves disclosures, or a written label advertisers put on videos, photos, or other content that shows it is an advertisement or “sponsored” post. Yet, we know that disclosures don’t work to keep kids safe from persuasive, stealth marketing– especially when it comes to influencer marketing.
So, on Monday, July 18, we filed comments to the FTC, calling on them to go beyond disclosures and ban influencer marketing because it is an unfair and deceptive practice. Over 20 organizations around the country signed on to our comments, including American Academy of Pediatrics, Eating Disorders Coalition for Research, Policy & Action, and ParentsTogether.
Here are some highlights from the comments:
Disclosures aren’t enough
Disclosures are not effective against stealth marketing like influencers because by design, stealth marketing works against people’s “cognitive defenses,” or their abilities to identify and rationalize away from the influence of the ad. Research shows that even adults often do not notice advertising disclosures. Young people face much greater challenges to seeing and remembering disclosures than adults. Young children cannot read written disclosures or may be distracted by other features of the content they are seeing, nor can they easily process the information. This leaves kids extra susceptible to marketing. While the FTC wants to rely on disclosures as a solution to protect kids, we know that this is not adequate.
Kids cannot fight influencer marketing
Influencers and trusted fictional characters like Spiderman are commonly used to market to young people because they are viewed as providing “authentic” communications from a trusted friend, rather than an advertisement. Research has shown that children and teens — even if they have developed advertising literacy skills — do not use those skills with influencer marketing! This means that influencers have extreme power over kids and can persuade them to buy or behave in ways that can be detrimental to themselves or others. We’ve asked the FTC to provide guidance to advertisers that they should not direct any stealth marketing to young people and to tell platforms not to show or amplify stealth marketing to kids and teens.
We look forward to the FTC’s virtual event on October 19, where we will come together with researchers, child development and legal experts, other consumer advocates, and industry professionals to examine the ways and impacts of advertising to children online and how we can continue to protect children from manipulative advertising. Stay tuned!